Eric D. Ryan · INSIGHTS Eric is a frequent speaker on international tax matters for several organizations, including the California Bar Association Tax Section, the Asia Tax Executives

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Tax

International Tax

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Tax Controversy and

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Transfer Pricing

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Eric D. RyanOf CounselCo-Chair, Global Transfer Pricing Practice

[email protected]

Eric Ryan concentrates in international tax planning, transfer pricing,post merger integration of legal entities, and operations and taxcontroversy.

Eric has over 25 years of experience, both as a tax partner advisor and an internal corporate tax

director, on key international tax structuring issues. His clients are primarily in the high

technology industry, including software, hardware, semiconductors and life sciences companies.

Eric's experience includes advising clients in choice of location for their operations; conducting

direct negotiations for tax holidays in countries such as Switzerland, Singapore and others;

advising on intercompany arrangements that minimize Subpart F and similar tax issues; and

advising on intercompany economic terms that seek to maximize profits in appropriate jurisdictions. He advises on the use of

holding companies, the valuation of transfer of tangible and intangible property, and the establishment of cost-sharing

operations. Eric is experienced in developments of advice pricing agreements (APA’s) and intercompany debt and equity.

Eric is a Pro Bono Coordinator for the East Palo Alto office, and he is also a member of DLA Piper's North American Pro Bono

Committee.

EXPERIENCE

On behalf of the Government of the United States Virgin Islands, Eric worked to obtain the favorable guidance from the US

Treasury and Internal Revenue Service ultimately contained within Notice 2006-76, relating to the qualification of certain

e-commerce business models for income tax exemptions in the USVI.

CREDENTIALS

AdmissionsCalifornia

Prior ExperiencePartner, Taxation, PricewaterhouseCoopers LLP (1994 – 2004)

Director of Taxes, Apple Computer (1983 – 1994)

As tax director for Apple Computer, Inc., Eric was responsible for the worldwide tax planning, compliance and audit defense

activity for this Fortune 100 company operating in more than 30 countries. He led that company’s efforts to respond to the IRS at

the exam, appeals and Tax Court levels. Eric was responsible for the efforts which led to the favorable Tax Court decision

regarding Apple's inclusion of stock option compensation in the qualifying base for R&E credits (Apple Computer, Inc. v.

Commissioner, 98 T.C. No. 18 (1992)). He was also the architect of the world’s first APA in 1991, between the US and Australia,

and later for others with Japan and Canada.

Recognitions

DLA Piper is a global law firm operating through various separate and distinct legal entities. Further details of these entities can be found at www.dlapiper.com. This may qualify as

“Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. Copyright © 2016 DLA Piper. All rights reserved.

Eric is listed as one of the pre-eminent practitioners in the Guide to the Worlds' Leading Transfer Pricing Advisors, published by

Euromoney. In 2006, he was recognized as one of the top tax lawyers in the Bay Area in a study published by Bay Area Lawyer

magazine.

EducationB.S., Accounting, Bradley University 1974

J.D., University of California at Berkeley 1977

CourtsUnited States Tax Court

MembershipsMember of San Jose State University Masters In Tax Program Advisory Board

American Bar Association, Taxation Section

California Bar Association, Taxation Section

Silicon Valley Tax Directors Group

Civic and CharitablePast President, Tax Executives Institute, Santa Clara Chapter

Advisory Board, Practical US/International Tax Strategies

INSIGHTS

Eric is a frequent speaker on international tax matters for several organizations, including the California Bar Association Tax

Section, the Asia Tax Executives Forum, and the Council for International Tax Education (CITE).

PublicationsTax Court invalidates cost sharing regulation on stock-based compensation. Now what?11 AUG 2015

Following this latest landmark victory on a long-disputed issue, multinationals with CSAs and SBC need to watch this area

closely and be ready to act

OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: keycomparisons19 MAY 2015While many provisions of CCAs and CSAs are similar, there are pronounced differences

"Intersport and Taxpayer-Initiated Transfer Pricing Adjustments," Tax Management Transfer Pricing Report, Vol. 21, No. 2, 17

May 2012

Events

PreviousMultijurisdictional tax: calls for reform1 APR 2016San Francisco

Global Tax Webinar: MAAL – the Australian Experience Webinar

Corporate tax update: what every corporate counsel needs to know6-7 OCT 2015East Palo Alto



Presenter, "Tax Litigation Update," TEI Santa Clara 3rd Annual Tax Controversy Seminar, September 27, 2016

Panelist, "Transfer Pricing & The Arm's Length Standard versus Formulary Apportionment," UC Hastings Business Law Journal

Tax Symposium, April 1, 2016

Speaker, "Reform for Our Broken Tax System--What and When?" The Federalist Society's Silicon Valley Lawyers Chapter,

Stanford University, November 17, 2015

Panelists, ''Cost Sharing Litigation Update: What You Should Know,'' Tax Executive’s Institute 3rd Annual Tax Controversy

Seminar, September 29, 2015

Presenter, "Cost Sharing and PCTs - Five Years Later," TEI Los Angeles Chapter - International Tax Seminar, Los Angeles,

September 25, 2015

Co-Presenter, "The Altera Decision and the Immediate Impact on Multinational Companies with CSAs and SBC," TEI Los

Angeles Chapter - International Tax Seminar, Los Angeles, September 25, 2015

Speaker, ''2015 Federal Tax Reform Proposals,'' TEI – SJSU Tax Policy Conference: Reinvigorated Tax Reform Arrives for

2015 - What It Means for You and Your Company, Santa Clara, May 15, 2015

Co-Presenter, "OECD Base Erosion and Profit Shifting (BEPS) Update," ASC 740 Accounting For Income Taxes Foreign Tax

Provisions And US International Tax Issues, Santa Clara, 3 Jun 2014

Speaker, "Handling IP Tax Controversies," Council for International Tax Education (CITE) Conference, San Francisco, 20 Mar

2012

Instructor, "Transfer Pricing," LLM Program, International Tax Center Leiden, The Netherlands, Jan 2012



Documents

Eric D. Ryan · INSIGHTS Eric is a frequent speaker on international tax matters for several organizations, including the California Bar Association Tax Section, the Asia Tax Executives